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Case 22-1426, Document ORAS 3536039 , Page174 of 217 59 M6SQOmaxS1 1 crimes. She has not owned up to the truth. She has lied 2 repeatedly. She has been dishonest with the Court, and she has 3 made misrepresentations when it suits her. Your Honor, we 4 recognize that the Court has calculated the guidelines to be 5 188 to 235 months. That is far below the sentence that the 6 government believes is appropriate in this case. We recognize 7 that there are a small number of cases where the Court imposes 8 an above-guideline sentenc This is that case, your Honor. g In the almost 20 years since the 2003 manual was 10 enacted, our Sentencing Commission, our Congress, and our 11 country have all recognized just how serious sex crimes against 12 children are. Our country now recognizes how woefully 13 inadequate the 2003 guidelines were, and the Supreme Court has 14 expressly held that sentencing courts can vary upwards for 15 exactly that reason. Again, this is that case. This is 16 exactly that case. This is the time to impose an 17 above-guideline sentenc A guideline sentence in this case 18 would create unwarranted sentencing disparities with 19 individuals being sentenced today for sex-trafficking offenses. 20 This case calls out for an above-guideline sentence because of 21 the breathtaking scope of the defendant's conduct, the length 22 of her crimes, the number of victims, the vulnerability of her 23 victims, the sophistication of the defendant's predatory 24 conduct and the degree to which she psychologically manipulated 25 her victims. Her conduct was shockingly predatory, and it SOUTHERN DISTRICT REPORTERS, (212) 805-0300 PeGu 0 DOJ-OGR-00021604